Privacy Statement

1. Introduction

Alpro (Alpro Comm.VA, company number 0420.429.375; Vlamingstraat 28, 8560 Wevelgem) knows that you care how your personal data is used and we recognize the importance of protecting your privacy.

This Privacy Statement explains how Alpro (as a controller) collect and manage your personal data. It contains information on what data we collect, how we use it, why we need it and how it can benefit you.

Contact us here if you have any queries and comments, or if you want to make a request regarding any of your data subject rights.

Alpro reserves the right, in its sole discretion, to change, modify, and/or add all or parts of this Privacy Statement, at any time. Any change to this Privacy Statement will be posted on this page. We encourage you to periodically review this Privacy Statement to stay informed about our information practices. We will indicate above the date on which this Privacy Statement was last modified. Your continued use of our websites constitutes your agreement to the Privacy Statement and any updates. If you do not agree to any changes, you must discontinue using our websites. This privacy statement was last updated on May 23, 2018.

2. Basic principles and our privacy commitment

At Alpro we are committed to protecting your right to privacy. We aim to protect any personal data we hold, to manage your personal data in a responsible way and to be transparent in our practices. Your trust is important to us. We have therefore committed ourselves to the following basic principles:

You have no obligation to provide any personal data requested by us. However, if you choose not to, we may not be able to provide you with some services or products;

We only collect and process your data for the purposes set out in this Privacy Statement or for specific purposes that we share with you and/or that you have consented to;

We aim to collect, process and use as little personal data as possible;

When we do collect your personal data, we aim to keep it as accurate and up to date as possible.

If the personal data we collect is no longer needed for any purposes and we are not required by law to retain it, we will do what we can to delete, destroy or permanently de-identify it.

Your personal data will not be shared, sold, rented or disclosed other than as described in this Privacy Statement.

3. What personal data do we collect?

The personal data we collect varies depending upon the purpose of the collection and the product or service we are providing you.

Generally, we may collect the following types of personal data from you directly:

Communications with us, which may include details of our conversations via chat, care lines and/or customer service lines;

Demographic information, such as your age and gender and lifestyle preferences. Lifestyle preferences may include your preference for some of the products we offer, and your interests related to those products;

Browser history, such as pages accessed, date of access, location when accessed, and IP address;

Information related to your health;

Information about people other than you, such as personal data about your family members, when you provide such information directly to us;

Social media profiles;

We may also collect personal data about you indirectly when:

you share content on social media pages, websites or applications related to our products or in response to our promotional material on social media; or

we read or collect personal data about you by reading information collected by other websites (for instance, we may place an ad on a third party website, and when you click on that ad, we may receive information about you and other website visitors in order to measure the reach and success of that ad).

4. Why do we collect and use your personal data?

We collect your personal data so we can provide you with the best online experience and to provide you with a high quality of customer service. In particular we may collect, hold, use and disclose your personal data for the following purposes:

To process and answer your inquiries or to contact you in order to answer your questions and/or requests;

To develop and improve our products, services, communication methods and the functionality of our websites;

To communicate information to you and to manage your registration and/or subscription to our newsletter or other communications;

To manage our everyday business needs in connection with your participation in our contests, sweepstakes or promotional activities or request;

To verify the identity or age of individuals contacting us by telephone, electronic means or otherwise;

For internal training and quality assurance purposes;

To understand and assess the interests, wants, and changing needs of customers, in order to improving our website, our current products and services, and/or developing new products and services;

to invite you or to allow you to participate in surveys or programs, or to notify you about special events by electronic mail or other electronic communication means (including e-mail, sms, etc.);

To provide personalized products and communications as well as product recommendations to you as customers;

to fulfill other purposes disclosed at the time you provide your Personal Data.

We may also need your personal data to comply with legal obligations or in the context of a contractual relationship that we have with you.

When we collect and use your personal data for purposes mentioned above or for other purposes, we will inform you before or at the time of collection.

Where appropriate, we will ask for your consent to process the personal data. Where you have given consent for processing activities, you have the right to withdraw your consent at any time.

Please note that it may be that some of the Personal Data you provide to us or that certain questions raised to participate to certain programs on our websites are considered as sensitive or health related Personal Data under applicable data protection laws. We shall only process such data when legally compliant on the basis of your express and written consent. Please note that by providing such information or answering such questions prior to the setting up the program and by accepting this Privacy Statement, you indeed give your express and written consent to the processing of such Personal Data (whether or not under the supervision of a health professional). Such consent is valid for the period of your registration to the program but you have the right to withdraw it at any time by contacting us as indicated in this Privacy Statement. Such Personal Data shall only be processed for the purpose of your participation in such program and access thereof shall be limited to persons with a need to know for the purpose of your participation in the program.

5. Your rights

Where we process your personal data, you are entitled to a number of rights and can exercise these rights at any point. We have provided an overview of these rights below together with what this entails for you. You can exercise your rights via our contact page Please note that for identification purposes, you should provide us with a copy of your valid ID card or any other valid identification document.

5.1. The right to access your personal data and correction

You have the right to access, correct or update your personal data at any time. We understand the importance of this and should you want to exercise your rights, please contact us.

5.2. The right to data portability

Your personal data is portable. This means it can be moved, copied or transmitted electronically. However, this right only applies where:

The processing is based on your consent;

The processing takes place for the performance of a contract;

The processing takes place by automated means;

If you wish to exercise your right to data portability, please contact us.

5.3. The right to deletion of your personal data

You have right to request that we delete your data if:

your personal data is no longer necessary in relation to the purposes for which we collected it; or

you withdraw the consent that you had previously given us to process your personal data, and there is no other legal ground to process that personal data; or

you object to us processing your personal data for direct marketing purposes; or

you object to us processing your personal data for Alpro’s legitimate interests (such as improving overall user experience on websites);

the personal data is not being processed lawfully; or

your personal data needs to be deleted to comply with the law.

If you wish to delete the personal data we hold about you, please let us know and we will take reasonable steps to respond to your request in accordance with legal requirements.

If the personal data we collect is no longer needed for any purposes and we are not required by law to retain it, we will do what we can to delete, destroy or permanently de-identify it. For direct marketing purposes, we will delete, destroy or permanently de-identify your personal data 3 years after the latest contact with you, unless shorter or longer retention periods apply under applicable law.

5.4. The right to restriction of processing

You have the right to restrict the processing of your personal data if:

you do not believe the personal data we have about you is accurate; or

the personal data is not being processed lawfully, but instead of deleting the personal data, you would prefer us to restrict processing instead; or

we no longer need your personal data for the purposes we collected it, but you require the data in order to establish, exercise or defend legal claims; or

you have objected to the processing of your personal data and are awaiting verification on whether your interests related to that objection outweigh the legitimate grounds for processing your data.

If you wish to restrict our processing of your personal data, please let us know and we will take reasonable steps to respond to your request in accordance with legal requirements.

5.5. The right to object

You have the right to object to the processing of your personal data, for which you can contact us at any time.

5.6. The right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint directly with the supervisory authority (www.privacycommission.be) about how we process personal data.

6. How we protect your personal data

We understand that the security of your personal data is important. We make our best efforts - and require the same from any service provider and/or third party processor processing Personal Data on our behalf and under our instructions - to protect your personal data from misuse, interference, loss, unauthorized access, modification or disclosure. We have implemented a number of security measures to help protect your personal data. For example, we implement access controls, use firewalls and secure servers, and we encrypt personal data.

However, no electronic transmission or storage of information is 100% secure. Therefore, despite the security measures that we have put in place to protect your Personal Data, we cannot guarantee that loss, misuse, or alteration of data will not occur.

7. Minors

Our websites are not directed at collecting Personal Data from minors (i.e. children under 18 years old). In order to protect minors, any visitor of our websites willing to participate to certain programs will have to communicate his/her year of birth in order to register for the program. Minors will not be allowed to register for the program. If we are notified or otherwise learn that a minor has submitted Personal Data to us through our websites, we will delete that minor's Personal Data.

8. Sharing of your personal data

When we share your personal data with affiliates and other organizations, we make sure we only do so with organizations that safeguard and protect your personal data and comply with applicable privacy laws in the same or similar way that we do.

Your personal data will not be shared, sold, rented or disclosed other than as described in this Privacy Statement.

Your personal data will be shared with the following third parties for the purposes described:

Third parties providing services on our behalf

We may employ third party processors or suppliers to perform functions on our behalf; examples include hosting or operating websites, fulfilling orders for products and services purchased through our websites, sending e-mail and/or other communications, providing wireless services, removing repetitive information from customer lists, data analysis, marketing assistance, credit card payment processing, and customer service. These third parties may have access to your Personal Data for the purpose of performing such functions on our behalf.

Alpro may also disclose your Personal Data to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to the Web Sites or the public.

Non-Personal Information

We may share non-personal information, such as aggregate user statistics, demographic information, and web site usage information with third parties, including affiliates and related companies of the group.

Contests and Promotions

We may offer contests, and other promotions through the websites that may require registration. If you choose to enter a contest or other promotion, your personal information may be disclosed to third parties in connection with the administration of such promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law, such as on a winners list.

Business Transfers

Alpro may share the Personal Data collected through the websites with and among the websites, and may share the Personal Data with its subsidiaries and affiliates. A list of these entities is available upon request. Alpro or any of it assets, including the websites, may be sold, or other transactions may occur in which your personal information is one of the key business assets for the transaction. In such a case, your Personal Data may be one of the business assets we transfer. Hence, Alpro reserves the right to disclose and transfer user information, including Personal Data, in connection with a merger, acquisition, sale of assets, joint venture, or any other transaction that results in a change in control or ownership of Alpro, in whole or in part; or in the event of a corporate reorganization, bankruptcy, insolvency proceeding, or similar circumstance, if permitted by and done in accordance with applicable law.

Legal Protections and Law Enforcement

We may disclose information about our users, including your Personal Data, in the event we are required to respond to subpoenas, court orders, legal process or other valid law enforcement measures; to comply with a legal obligation; at the request of governmental authorities conducting an investigation; to verify or enforce compliance with the policies governing the websites and applicable laws; or to protect the legal rights, interests, or safety of our websites, our users or others. We may also use Device Identifiers to identify users, and may do so in cooperation with copyright owners, internet service providers or law enforcement agencies in our discretion. Such disclosures may be carried out without notice to you.

9. Sharing data internationally

Personal data will normally be processed within the European Economic Area (EEA). When exceptionally processed outside the EEA, Alpro will make sure that this cross-border data processing is protected by adequate safeguards.

The safeguards that we use to protect cross-border data processing include:

Model Contractual Clauses approved by European Commission. These standardized contractual clauses provide sufficient safeguards to meet the adequacy and security requirements of the European General Data Protection Regulation; or

certifications which demonstrate that third parties outside of the EEA process personal data in a way that is consistent with the European General Data Protection Regulation. These certifications are approved either by the European Commission, a competent supervisory authority or a competent national accreditation body in terms of General Data Protection Regulation.

10. Link to other websites

Our websites may provide links to third party websites as a service to our visitors. This may include links from advertisers, sponsors and partners. This Privacy Statement does not apply to those websites. These websites operate independently and are not under our control. These websites may have their own privacy notices in place, which we strongly suggest you review if you visit them. Please review the privacy statement and terms of use posted on each website you visit. We are not responsible for the content of these websites, any products or services that may be offered through these websites or any other use of these websites nor for any data processing and privacy practices associated with such websites.

11. Automated decision-making and profiling

For some services and products we and our third-party service providers may process your personal data using automated means. Such information may consist of your internet browser type, operating system, service provider, the web pages you viewed, the time you viewed them and for how long, demographic information about you (such as your age, gender, language, location and interest areas, where available) and what web pages you looked at before viewing the current page. We use this information to get a better idea of how our users interact with our web sites and then tailor and improve our websites accordingly. Such information generally cannot be linked to you individually, but if we can link it to you then we treat it as your Personal Data in accordance with this Privacy Statement.

We may also process your personal data for profiling purposes to predict your behavior on our website and targeted marketing activities for our products that may be of interest to you.

You can object to these processes in advance. You are also free to contact us for further information on such processing.

12. Cookies and other technologies

We may also collect personal data about you through the use of cookies and other technologies. Cookies are files that web servers place on your device. The use of cookies on the website allows you to enjoy more seamless visits and measures your behaviour on the website more accurately.

This may occur when you visit our sites or third-party sites, view our online promotions, or use our/third-party mobile applications and may include the following information: